Attendees listened to a panel organized by The Pesticide Stewardship Alliance (TPSA), which outlined best practices for mini-bulk/IBC container compliance, including how to bring refillable containers into compliance, as well as ways to recycle noncompliant containers.

Hovis, Stewardship and Technical Issues Manager at Bayer CropScience, presented the mission and role TPSA serves in leading pesticide stewardship. TPSA is a unique collaboration of federal, state and local government agencies, educational and research organizations, public organizations, private corporations including chemical and container manufacturers and recyclers and individuals, and is actively involved in the many aspects of pesticide stewardship.

The goals of TPSA are “to serve as a forum to facilitate cooperation amongst various interested individuals, as well as educating and training to increase the effectiveness, efficiency and longevity of various pesticide stewardship efforts.”

TPSA defines pesticide stewardship efforts as “any activity that has a positive impact on the safety and efficacy of pesticides from manufacture, marketing and commerce, through storage and use, and ultimately the disposal of unwanted or unusable products and the management of empty mini-bulk containers.”

Container Stewardship

Fitz, a chemical engineer at EPA’s Office of Pesticide Programs, said one of the first steps in container stewardship is to determine whether or not a container is subject to EPA container regulations.

“If the container is intended for sale or transfer to another party, the container is subject to all applicable pesticide container and repackaging regulations,” she said. “If the container is being filled as a “service container” (a container filled with pesticide by the applicator for the sole purpose of that applicator applying the pesticide), then the container is not subject to EPA regulations. Although EPA believes it is a best management practice to ensure the contents are identified and labeled regardless of whether it’s a service container or not.”

Fitz also said it’s important to determine whether the container is labeled as either refillable or non-refillable, and whether the container meets certain EPA standards for pesticide use. Portable refillable containers are also regulated.

When filling a refillable container, Fitz said there are certain EPA-sanctioned procedures the operator must follow, including:

Visually inspect container each time prior to refilling.

Clean the container when necessary.

Ensure proper labeling.

Seal the fill port to the container manufacturer’s instructions.

EPA also requires container refillers to keep detailed and organized records of the process, Fitz said. More information is available on the EPA site.

Continued Use

The Department of Transportation (DOT) also has regulations in place that pertain to continued use of an Intermediate Bulk Container (IBC) that has previously been in service, said Knelle, Regulatory Affairs & EHS Manager at Tri-Rinse.

“Assuming the container is an IBC and composed of metal, rigid plastic or composite materials, according to DOT the IBC must be leak-proof tested prior to its first transportation and every two and a half years thereafter,” he said.

Leak-proof testing consists of replacing vented closures with non-vented, requires the use of air pressure equal to or greater than 20kPa (or 2.9 pounds per square inch [PSIG]) for a suitable length of time and visibly checking seams and joints for leaks.

Internal inspections, which consist of looking for cracks, warpage and corrosion or other defects, are also required every five years, Knelle said.

After testing is complete, the tester is responsible for durably marking the IBC with the following information: the country where maintenance occurred, name of party performing the maintenance and the date of retesting.

Aside from the containers themselves, pumping equipment must be maintained to a certain standard as well, Knelle added.

Anderson, National Accounts Manager at FarmChem, also presented how-to videos on bringing containers into compliance during the Webinar.

End Of Service

Mini bulk and IBC recycling is yet another aspect of container compliance governed by a myriad of regulations, said Birchfield, Environmental Stewardship & Emergency Response Manager at Syngenta.

“When preparing an IBC for recycling, any item that will not be recycled or further disassembled needs to be removed,” he said. “Generally speaking, cages on caged tanks do not need to be removed. DOT Hazmat labels must also be removed, while the pesticide label must remain intact.”

The preferred method of recycling depends on the IBC’s design and composite material, Birchfield said. Users are advised to follow the American National Standards Institute (ANSI) and American Society Of Agricultural and Biological Engineers (ASABE) standards for recycling pesticide and adjuvant containers.

As TSPA continues to “take the industry lead for efforts associate with container compliance and recycling efforts,” Birchfield said the organization is developing a list of companies and organizations actively recycling mini bulk and IBC pesticide containers to be posted on its website in March.